Our Corporate Governance

We follow the strictest custodial guidelines and corporate governance to ensure the integrity and safety of the gold and silver in your Clear Title Account. To uphold this commitment, we have adopted a Code of Business Conduct and Ethics (the “Code”).

Compliance Officer Responsibilities

Our Corporate Compliance Officer brings over 30 years of experience at the senior executive level in financial services operations. The Senior Management Committee, along with the Compliance Officer, operates under strict corporate policies to maintain the integrity of client bullion and cash holdings within all Clear Title Accounts. We regularly review our written compliance policies, which are part of the Code. The Code includes specific policies for handling and safeguarding material, non-public information. Additionally, the Compliance Officer ensures that all key personnel adhere to these policies, safeguarding confidential information at all times.

Corporate Risk Management

At Strategic Gold Corporation, we believe risk management is central to our mission. We established the company to respond to the systemic risks that became apparent during the financial crisis of 2007-2009. These risks, we believe, still pose ongoing threats to the financial system today.

Direct Ownership of Assets

We know that the best protection against systemic risk comes from directly owning reserve or safe-haven assets held outside the financial system. Physical gold and silver, in particular, meet this criterion because they are non-financial assets that remain highly liquid and easy to store outside of traditional financial structures. Therefore, we developed a comprehensive Enterprise Risk Management (ERM) program that equips us to protect our clients and manage risks proactively. This program integrates risk control into daily operations, ensuring that everyone at the company takes responsibility for identifying and addressing risks.

ERM Integration in Daily Operations

By incorporating risk management into our daily business practices, the ERM program ensures that we uphold the highest ethical standards aligned with the core values of our corporate governance. We apply both “top-down” and “bottom-up” approaches to measure and respond to risk exposures at the client account and enterprise levels. This continuous process helps us improve risk controls and identify new opportunities for our clients. Because risk management is an ongoing process, our ERM program evolves with new opportunities and emerging threats.

Moreover, the ERM program enables us to anticipate and act on potential opportunities. This proactive approach not only mitigates risks but also challenges conventional thinking to create better solutions for our clients. As risk management is cyclical, our program constantly updates to address changes in the risk landscape.

Independent Bullion Auditor

Bureau Veritas, our Independent Bullion Auditor, performs regular sight verification of all bars and serial numbers. They ensure that Strategic Gold’s inventories match client accounts. This independent verification happens twice a year, and each client receives a personal audit report alongside their quarterly account statement, ensuring complete transparency.

At all times, clients own a clear, unencumbered, and defined amount of gold or silver bullion. These holdings are stored in accredited vaults, fully insured, and meet investment-grade ‘Good Delivery’ standards.

Independent Transaction Auditor

Ensuring Transparency and Security

We remain committed to maintaining the highest levels of transparency while ensuring privacy and security for our clients. Therefore, we have established a governance and audit control system to protect client assets. Strategic Gold works with Livingston and Haynes, an Independent Transaction Auditor, to verify all client transactions and prevent unauthorized cash or bullion withdrawals.

Key Policies

This policy ensures:

1. Client transactions are properly authorized.
2. Client assets are safeguarded against unauthorized or improper use.
3. Transactions are properly recorded and reported.

Client Funds

Secure Segregation of Client Funds

We segregate client funds in a secure bank account, applying a two-man rule to ensure maximum security. Every transaction requires verification from both the Independent Transaction Auditor and a Strategic Gold officer. This policy guarantees that your funds always remain under your direct control and ownership. Strategic Gold acts only on your verified written instructions, authorized by the Independent Transaction Auditor.

Bullion Delivery Withdrawals

Similarly, all bullion in your Clear Title Account remains your property and under your control. Strategic Gold only acts on your verified written instructions, as confirmed by the Independent Transaction Auditor. This oversight ensures that your bullion assets are always under your control.